Walser v. Toyota Motor Sales, U.S.A., Inc.

After a Toyota representative mistakenly told prospective franchisees Walser and McLaughlin (plaintiffs) that their letter of intent had been formally approved, only to retract that statement two days later and explain additional financial conditions still needed to be satisfied before a formal dealership agreement could ever be reached, Toyota ultimately withdrew from the deal entirely; Walser and McLaughlin, who had already purchased property for the proposed dealership, sued for breach of contract, promissory estoppel, and fraud, seeking lost profits. The jury, instructed to limit promissory estoppel damages to out-of-pocket expenses measured by the property's purchase price versus its actual value, awarded roughly $230,000, and Walser and McLaughlin appealed the damages limitation.